The signal from the latest Plenary
FATF’s agenda continues to intensify around transparency and effectiveness. Jurisdictions are
being pressed on UBO registries, virtual asset supervision, and sanctions implementation. Here’s
what the outcomes mean for compliance teams.
Beneficial ownership (Recommendation 24)
Countries are moving from “collect something” to useful and up‑to‑date registers.
Program move: document how you resolve UBO conflicts across sources and set a
review cadence when high‑risk indicators change.
Virtual assets & Travel Rule
Expect enforcement on originator/beneficiary data transfer and screening of unhosted wallets.
Program move: record your counterparty assurance steps for VASP‑to‑VASP flows,
and define a policy for transactions when Travel Rule data is missing.
Grey‑listing and de‑risking
Examiners are asking how firms avoid blunt country exits. Program move: keep a
documented risk rationale, enhanced due diligence options, and exit criteria.
Readiness checklist
- Map controls to the latest FATF priorities and your supervisor’s Dear CEO letters.
- Evidence Travel Rule compliance and exception handling in case files.
- Track exposure to newly monitored jurisdictions and plan mitigations.
Takeaway: keep a documented “FATF tracker” and show how it drives concrete control
changes each quarter.